On 11 December 2015 the Ministry of Finance of Ukraine and the Ministry of Energy, Trade, Industry and Tourism of Cyprus signed a Protocol amending the Double Tax Treaty between Ukraine and Cyprus (DTT).

If ratified by the Ukrainian and Cyprus parliaments, the following changes to the DTT will become effective on 1 January 2019:

  • Capital gains from sale of shares which derive more than 50% of their value from immovable property situated in Ukraine will be taxed in Ukraine at 15% WHT;
  • In order to apply 5% WHT on dividends distributed to Cyprus the investor will be required to: (i) hold at least 20% of the company’s shares and (ii) make an investment of at least 100,000 EURO into the company’s capital;
  • The WHT on interest payments will increase from 2% to 5%.

We will continue to monitor the status of the tax treaty in order to provide you with further updates.


Camiel van der Meij, Partner & TLS Leader, camiel.van.der.meij@ua.pwc.com
Slava Vlasov, Partner, Tax and Legal Services, slava.vlasov@ua.pwc.com
Oksana Borovets, Senior Manager, Tax and Legal Services, oksana.borovets@ua.pwc.com

75 Zhylyanska Street | Kyiv | Tel:  +380 44 354 0404 | Fax: +380 44 354 0790 | pwc.ukraine@ua.pwc.com |  www.pwc.com/ua 

This flash report is produced by PricewaterhouseCoopers’ tax and legal services department. The material contained in this alert is provided for general information purposes only and does not contain a comprehensive analysis of each item described. Before taking (or not taking) any action, readers should seek professional advice specific to their situation. No liability is accepted for acts or omissions taken in reliance upon the contents of this alert.
© 2015 Limited liability company «PricewaterhouseCoopers». All rights reserved. PwC refers to the Ukrainian member firm, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see www.pwc.com/structure for further details.

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